Appellate Court Affirms Appeal in Florida Car Accident Case

Recently, the district court of appeals for the State of Florida Fifth District issued an opinion in an appeal involving a negligence claim by the appellant, the plaintiff, against the appellee, First Team Ford, LTD d/b/a Autonation Ford Sanford, a Florida Limited Partnership (the Dealership). Ryan Matthews, the general manager of the Dealership drove a Ford Expedition owned by the dealership home one day. On his drive home, he got in an automobile accident with the plaintiff. As a result of the accident, the plaintiff filed a complaint against Matthews and the Dealership, alleging a negligence claim against Matthews, and a vicarious liability claim against the Dealership. The plaintiff settled with Matthews and the case proceeded solely against the Dealership. At trial, the court entered a final summary judgment in favor of the Dealership.

Facts of the Case

On December 21, 2016, Matthews, the general manager of the Dealership, drove his wife’s vehicle, a Chevy Tahoe, into the dealership. Matthews testified that he brought the Chevy Tahoe into the Dealership to get the oil changed, but also that he was interested in purchasing a Ford Expedition, and used this as an opportunity to test one out. While there, Matthews executed a “Loaned Vehicle Agreement” in order to drive home a Ford Expedition owned by the Dealership. Matthews left the Dealership driving the Ford Expedition. On the drive home, Matthews got into a car accident with the plaintiff. The plaintiff filed a complaint against both Matthews and the Dealership, alleging negligence by Matthews and vicarious liability against the Dealership under Florida’s Dangerous Instrumentality Doctrine. Matthews and the plaintiff settled, leaving only the case against the Dealership.

At trial, following the discovery process, both parties filed motions for summary judgment. The Dealership argued that the plaintiff’s claim was barred by the Graves Amendment. In particular, the Dealership argued that the Graves Amendment shields owners of rented or leased vehicles from damages caused by the vehicle while it is leased or rented. The Dealership argued that it rented the Ford Expedition to Matthews, while his vehicle was being serviced. The plaintiff argued that Matthews’ use of the Ford Expedition was solely for a test drive and that the Chevy Tahoe was never serviced on the day of the accident. The plaintiff further argued that any intent by Matthews to have his vehicle serviced was undermined by inferences drawn from the record. The plaintiff asserted that because the Graves Amendment does not apply to gratuitous test drives, a genuine dispute of material facts existed, which precluded summary judgment in favor of the Dealership. Following a hearing for both motions, the trial court entered an order granting the Dealership’s motion for summary judgment.

On appeal, the plaintiff asserted that the trial court erroneously granted summary judgment when there was a genuine dispute of material fact as to whether Matthews intended to have his Tahoe serviced at the Dealership. The Dealership, on the other hand, argues there are no genuine disputes as to any material fact. The appellate court decision states that the trial court erred by granting summary judgment in favor of the Dealership due to the genuine dispute of material facts. The appeals court found that Matthews’ deposition raised a genuine dispute of material fact as to his purpose in executing the “Loaned Vehicle Agreement.” Further, the record brings Matthews’ reason for bringing in the Chevy Tahoe. Finally, the appellate court found that the trial court impermissibly relied on the intent of Mr. Matthews when it decided that there was no dispute as to any material fact. As a result, the appellate court reversed the lower court decision.

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